Research & Insights

Sustainable Investing & ESG Policy

Sustainable investing is a strategic priority for Bridgewater. Our approach is shaped both by who we are as an investment manager—a global macro investor with a fundamental, systematic, and diversified approach to investment research and portfolio construction—and by how we partner with clients.

As a global macro multi-asset manager, our first investment goal is to build a deep understanding of how economies and markets work. Because issues relating to environmental, social, and governance dynamics often impact global economies and markets, we have made it a priority to deeply research these issues and to integrate that research into our investment process in a manner that is consistent with our systematic way of managing money. We believe our research approach is well-suited to explore the fundamental environmental- and social-related linkages at play in the same way we study other cause-and-effect linkages in the global economy and markets.

Our second goal is to convert that understanding into high-quality solutions for our clients’ most important investment objectives. The framework we use for integrating environmental and social considerations depends on the objectives of a given portfolio. For portfolios with only traditional return and risk objectives, we research environmental and social issues that may have a material impact on financial performance, and this research is integrated where relevant as part of our broader investment process. For example, we have researched the economic and market implications of climate risk and the transition to a net zero emissions economy and incorporated this research into our global, multi-asset active strategies in the form of risk controls. Alongside return and risk considerations, an increasing number of clients have added impact to their investment objectives, and we are partnering with clients to consider not only how environmental- and social-related issues might affect return and risk but also how to construct portfolios aligned with environmental and social outcomes. We now have two strategies that explicitly seek to achieve return, risk, and impact objectives—All Weather Sustainability and Active Sustainable Equities—while our other strategies do not have any explicit impact or sustainability goals.

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Karen Karniol-Tambour (co-CIO) and Carsten Stendevad (co-CIO for Sustainable Investing) co-chair our Sustainable Investing Committee, which is responsible for overseeing Bridgewater’s Sustainable Investing and ESG Policy, for all aspects of the design and oversight of our sustainable portfolios (such as Active Sustainable Equities and All Weather Sustainability), for ensuring that material topics relating to social and environmental issues are integrated into Bridgewater’s investment processes, as well as for the firm’s stewardship activities. The Sustainable Investing Committee also includes our Head of Sustainability Research, Daniel Hochman, and is supported by a dedicated team of roughly 20.

With respect to our sustainable portfolios, Karen and Carsten are responsible for all aspects of the investment process including portfolio design, security selection, sustainability logic, portfolio construction and implementation. They are responsible for all sustainability-related research and systems, for drawing in return streams and alpha signals from across Bridgewater research teams (e.g., equities, FX, commodities, rates, macro), for adding portfolio- and holding-specific alpha insights as relevant, and for 3D portfolio construction processes, including integrating alpha signals and sustainability signals to build sustainable portfolios.

As co-chairs of the Sustainable Investing Committee, Carsten and Karen provide regular business updates to the Executive Committee (which is chaired by the CEO), as well as regular updates to Bridgewater’s Investment Committee, which may result in updates to the policy. The overall policy and any changes are also periodically reviewed by Bridgewater’s legal and compliance team.

2-D Approach: Environmental and Social Integration (Return and Risk)

Our starting point as investors has always been to understand how the world works. In service of that mission, we conduct deep, fundamental research across a broad range of topics—we believe markets and economies move for logical reasons that can be studied and understood, and once we understand how something works, we systemize that understanding into our investment process and compound on it through time. We then convert that accumulated understanding into insights and portfolio solutions for our clients. In addition, we share important findings from our research with our clients and, in a number of cases, policy makers and the public at large.

Because the core of our investment approach is to deeply understand global economies and markets, it is inherently important for us to understand environmental and social dynamics. Environmental- and social-related considerations can directly impact economic and market outcomes as well as the actions of policy makers. As such, we seek to deeply understand these topics by studying them as an integrated part of our research process and prioritize topics that we believe are most pertinent to our macro investment approach—in other words, those topics we think have material financial (return/risk) relevance to our portfolios.

Since many environmental and social issues have macro linkages, we believe that we are well-positioned to explore the fundamental cause-and-effect relationships at play. Leveraging our nearly 50 years of experience in conducting deep, systematic macro research, we study a wide range of topics related to these issues, such as the divergences between social and economic conditions, populism and social inequality, the economic impacts of climate change, and the shift toward renewable energy and the implications of the world transitioning away from fossil fuels, to name a few.

Furthering our understanding of environmental and climate change considerations is a priority for us. Climate change will be one of the defining issues of the 21st century, and addressing it will create significant shifts in the underpinnings of the global economy. A successful transition away from carbon will require major responses from governments, companies, investors, and other actors around the world. From an investor perspective, climate change is a multidimensional topic that affects asset markets and economies through many different channels, such as direct physical effects (e.g., rising temperatures and related effects) as well as through the impact on transition-related regulation, investment, capital flows, changes to commodity consumption, etc. We have investigated a wide range of climate-related issues, such as the distribution of greenhouse gas emissions and associated risks in the economy and investor portfolios, the risks to assets and portfolios under different possible climate transition scenarios, the inflationary effects of climate-related regulations, the impact of the shift toward greener energy sources on oil and industrial metals, China’s shift toward renewable energy, the implications of the decline of coal, as well as fundamental challenges with macroeconomic modeling of physical climate risks.

In recent years, we have also researched how social issues are increasingly impacting economic and market outcomes. For example, our researchers perceived that the growing divergences across households of different income and wealth levels were making some aggregate economic statistics (e.g., GDP growth) less useful as indicators of future spending. This perception led us to questions about not only the accuracy of our spending estimates but also the effects of inequality on social cohesion, populism, and conflict. The answers to these questions are critical for understanding the investment landscape, as these issues are increasingly influencing the decisions of monetary and fiscal policy makers.

As new understanding is uncovered, we seek to systemize and incorporate it into Bridgewater’s broader understanding of how markets and economies work and utilize it to trade markets. For example, our research into low-carbon economy scenarios flows into our projections on the impact of demand for commodities (e.g., industrial metals and energy). We also seek to incorporate our understanding of environmental and social issues into our fundamental risk controls process. For example, we utilize our understanding of how our various asset holdings around the world would perform under different climate transition scenarios (e.g., a faster shift to a low-carbon economy) to build risk caps tailored to climate risks.

In general, the research we publish provides the best window into the types of environmental- and social-related research that we prioritize incorporating into our investment systems. As mentioned above, we share research throughout the year via the Daily Observations and synthesize our views on an annual basis to our clients in our Sustainable Investing Annual Report.1

3-D Approach: Building Portfolios to Achieve Financial and Impact Goals

Alongside return and risk considerations, an increasing number of institutional investors are focused on a third dimension—the impact that their portfolios have on environmental and social outcomes. These investors explicitly want to direct capital toward the types of investments that are most aligned to their impact objectives, while at the same time achieving their financial goals. As our clients started adopting such impact goals, we did what we have always done and partnered with them to build portfolio solutions designed to achieve their aims.

We are committed to designing 3-D strategies that pursue the variety of impact goals that are most important to our clients. Our first 3-D portfolios focus on alignment to the UN Sustainable Development Goals as their impact objective. We find the UN SDGs to be a valuable, comprehensive framework spanning both social and environmental outcomes (including net zero), and we are working with clients committed to SDG alignment in their portfolios. Some investors are particularly focused on the impact on climate change and have made net zero commitments—we are committed to partnering with clients by designing portfolios specifically tailored to this goal.

While it is almost impossible to measure the sustainability impact of any one public market transaction, actions across asset owners, managers, and other players in the financial system can collectively impact the cost and availability of capital for issuers, as well as broader stakeholder alignment. The Paris Agreement on climate change explicitly notes the importance of “making finance flows consistent with a pathway toward low greenhouse gas emissions and climate-resilient development” (Article 2.1). Given the difficulty of attributing impact to any one financial transaction, we describe the impact dimension of our 3-D portfolios in terms of alignment to impact goals.

Using Bridgewater’s fundamental, systematic, and diversified approach to investment research and portfolio engineering expertise, our Sustainable Investing team is responsible for designing and managing these portfolios with explicit sustainability goals. We have built a systematic assessment process for evaluating the alignment of securities across asset classes with the SDGs and net zero, as well as the trajectory of issuers’ sustainability improvements. Further, we have developed what we call 3-D portfolio construction—bringing together our sustainability insights with our decades of portfolio construction expertise in order to design portfolios to realize explicitly identified return, risk, and impact goals.

The All Weather Sustainability Strategy is our first portfolio that deploys this sustainability assessment process and is designed to be a strategic (beta) portfolio solution for investors who seek to achieve both financial and impact goals at scale. We chose to focus on building a strategic portfolio because ~90% of the risk in typical institutional portfolios is in the strategic asset allocation, so engineering a quality strategic asset allocation represents a crucial foundation for investors’ financial and impact goals. The strategy is designed to generate a higher ratio of return to risk than traditional portfolios by employing Bridgewater’s All Weather approach of balancing risk across economic environments, while holding only assets that are positively aligned to the UN SDGs or are on a clear and credible pathway toward SDG alignment, rather than excluding only the least aligned.2

Active Sustainable Equities, the second 3-D portfolio that we have built, is an actively managed, long-only, sustainable equities strategy. It is designed to outperform global equities by expressing Bridgewater’s decades of macro understanding and alpha insights at the individual equity level, while holding only equities that meet our high bar for sustainability, i.e., are either currently aligned with or on a clear and credible path toward becoming aligned with the UN SDGs and, as an integral part of the overall framework, the transition to a net zero emissions world. We see this strategy as the natural second step for us in our journey to provide portfolio solutions that help clients achieve both their financial and sustainability goals, utilizing our edge in markets, our systematic sustainability assessment process, and our 3-D portfolio construction capabilities.

Stewardship and Corporate Engagement Policy

Bridgewater’s Stewardship and Corporate Engagement Policy is set, implemented, and overseen by the Sustainable Investing Committee, and it spans corporate engagement, proxy voting, and partnerships and collaborations with a broad range of industry actors, including data providers, research institutions, industry partners, and our clients. The policy adheres to the guidelines of the Principles for Responsible Investing (PRI) and aligns to the recommended framework of the Task Force on Climate-Related Financial Disclosures (TCFD). The goal of our stewardship activities is to advance the objectives of our respective portfolios (risk-return for those with financial goals; risk-return-impact for those with financial and sustainability goals).

Our stewardship and collaborative engagement efforts focus on a set of cross-cutting themes, including environment-related risks (e.g., transition to a low-carbon economy), social-related risks (e.g., modern slavery), and governance and transparency-related risks (e.g., sustainability disclosures). Our Sustainable Investing Annual Report, which we will publish in 2023, will detail our 2022 activities.

Below, we provide more details on our approach to corporate engagement, proxy voting, and industry collaborations.

Corporate Engagement

Our Philosophy and Objectives: We believe in the value of constructive engagements between companies and investors to drive both financial and sustainability objectives. As described above, the policy adheres to the guidelines of the PRI, aligns to the recommended framework of the TCFD and has two overarching objectives: advancing our portfolio objectives across return and risk (as well as impact in the case of sustainable portfolios), as well as improving our understanding of company-specific sustainability issues. Our Sustainable Investing Committee is responsible for our overall engagement strategy, including prioritizing thematic areas, selecting target companies, and overseeing the integration of engagement outcomes into our systems.

Our Thematic Approach: Because our equity exposures across our various portfolios tend to be highly diversified with small ownership stakes, we have chosen to engage thematically via our partnership with our engagement services provider, Sustainalytics. By approaching these engagements thematically, we aim to think broadly and deeply about the challenges that companies are facing, play a role in helping to shape industry standards and best practices, and be more targeted in specific conversations. We prioritize our engagements based on both the cross-cutting themes we identified above as well as sectors that are critical to their advancement. We will share thematic observations to our clients in our forthcoming Sustainable Investing Annual Report.

For companies that we hold in our sustainability-focused strategies like All Weather Sustainability—or for those that are close to our sustainability bar and that we are considering holding if they demonstrate significant sustainability improvement potential—we leverage our systematic sustainability process to identify specific situations where we believe our engagement might help enhance their sustainability profile. These engagements are carried out in line with recommendations and best practices from industry groups such as PRI or net zero alliances, and often focus on companies with potential for the largest real-world decarbonization impact across multiple points in the supply chain (e.g., ranging from raw materials providers to manufacturers and consumers of climate solutions).

We focus on these issues during our targeted engagements, and we integrate learnings from the dialogue back into our systematic company assessments, in essence “closing the loop” across our end-to-end sustainability process. We also maintain an internal “watchlist” of companies that represent the highest priority for engagement, e.g., due to prior net zero or ESG commitments they have made that we are monitoring. For certain sectors (e.g., autos), we have been able to identify “improvers” that are on a clear and credible pathway to increasing the sustainability of their products/services or business behavior, while for other sectors (e.g., financials) the progress is in its earlier stages. Although we are early in the journey on company engagement, we are deriving tangible value from these corporate engagements in terms of advancing our impact objectives and improving our understanding of company-specific sustainability dynamics.

Implementation and Execution: We partner with an engagement services provider—Sustainalytics—to design and execute our engagements (company outreach, meeting coordination, documentation) and align our focus areas with other investors to strengthen our collective messaging. Our partnership with Sustainalytics is centered on a rigorous and constructive approach to engagement, which aims at encouraging companies to improve their approach to the chosen themes, aiming towards reduced reputational and operational risks as well as raising standards at the sector level. In addition to participating in engagements facilitated by Sustainalytics, we also conduct a handful of bilateral conversations with the board members, CEOs, and executives where we have existing relationships.

We take a very hands-on approach to working with Sustainalytics. At the strategy level, we have shared our policy with their leadership team and hold regular executive-level conversations regarding our philosophy, approach, and priorities. At the operational level, we also hold direct, active discussions with Sustainalytics’ engagement managers, in which we share our list of target companies (based on our systematic analysis of ESG behavior), discuss appropriate KPIs, step back on the progress of existing engagements, and discuss potential areas for improvement. We have found it valuable to engage with a broad range of companies from industry leaders to laggards, both because all companies have potential to improve on an absolute basis and because it gives us valuable insights into relative strengths and weaknesses. Members of our Sustainable Investing team (including a co-chairs of the Sustainable Investing Committee and Head of Sustainability Research) actively participate in the dialogues with companies. Facilitated by Sustainalytics, we have met with a range of company representatives from board members, CEOs, company secretaries, and C-suite executives to investor-relations and sustainability executives. Through our engagement services provider, we may choose to participate with other investors in conducting these engagements, but we will always retain our full discretion to act however we see fit and thus are not acting as a formal consortium.

Per the above, we report on the progress of our corporate engagement objectives, focus areas, and outcomes to our clients on annual basis.

Proxy Voting

Proxy voting in an integral part of our approach to stewardship. Similar to our corporate engagement efforts, this policy is set, implemented, and overseen directly by our Sustainable Investing Committee. Additionally, we partner with Glass Lewis, a proxy advisor, to implement and vote our shares on behalf of our clients. Glass Lewis is a signatory to the PRI, abides by the principles set forth therein, and considers ESG issues in the process of generating all of their recommendations.

We have shared our policy with Glass Lewis and meet on a biannual cadence with their research team to discuss our philosophy, probe into their various policies and provide our feedback, and exchange views on key priority areas for the year ahead. We use these sessions to ensure that Glass Lewis’ policies are aligned with our portfolio objectives. On an ongoing basis, we monitor and review key upcoming votes and review the Glass Lewis recommendations—in particular, those that have been flagged as “controversial” or that affect key holdings in our portfolios. We also review the feedback statements that companies send to Glass Lewis on their ratings and recommendations to gauge constructive engagement and understand which companies are on a path to improvement.

When voting on environmental, social, and governance proposals, we apply rules that are specifically aligned with the objectives of each strategy. To do this, we maintain a close dialogue with Glass Lewis to understand their process for evaluating each individual vote throughout the year, in addition to monitoring controversial or high-profile votes, and perform a comprehensive review of our voting rules and activity at the end of the year to ensure they remain aligned with the goals of our strategies.

For our portfolios with financial objectives only, we apply Glass Lewis’ Standard policy but with an enhanced focus on climate-related risks in those companies and sectors where they are financially material. This is aligned with the recommendations of the TCFD. For our sustainability-focused strategies such as All Weather Sustainability, we have directed Glass Lewis to employ their explicit ESG proxy policy, which entails a particularly strong focus on environmental and social issues and company disclosures. We maintain a high bar for companies in these strategies, and we seek to hold them accountable to the highest possible standards on sustainability.

Details on our voting records are available to our clients in our Sustainable Investing Annual Report.

Additional detail on our proxy voting practices can be found in our proxy voting policy, which is available in our Form ADV 2A on the SEC’s website or upon request.

Industry Collaborations

Industry collaborations are an important part of our sustainability efforts. As a research-driven firm, we are constantly in pursuit of new insights, which we triangulate, test, and validate by comparing many diverse perspectives and explicitly drawing on external experts. Our collaborative efforts span engagement with many types of institutions. Our clients are our closest collaboration partners, and we work with them on a broad range of issues, such as how to engineer sustainable portfolios, how to stress test portfolios to climate change scenarios, and evaluating sustainability data. More broadly, we seek to collaborate with thought leaders in the global sustainable investing community—including academics, research institutions, NGOs, and data providers on initiatives that align closely with our research objectives. We pursue all these collaborations in the spirit of our PRI commitment to work with others in the industry to enhance our collective effectiveness in integrating sustainability considerations into our investment processes.

Most of our collaborations have centered on the theme of improving the quality and availability of sustainability data, through the harmonization of sustainability standards and enhanced corporate disclosures. Drawing from global best practices, we also aim to bridge different stakeholders and multidisciplinary circles through our engagements.

For example, we have been involved in a collaboration on modern slavery risk assessment growing out of the Brookings Institution’s and Rockefeller Foundation’s 17 Rooms initiative and we are a member of the Investment Leaders’ Group (ILG) convened by the University of Cambridge Institute for Sustainability Leadership (CISL).

In terms of external affiliations, Bridgewater is a signatory to the Principles for Responsible Investment, a supporter of the Task Force on Climate-Related Financial Disclosures, a core supporter of the Standards Board for Alternative Investments (formerly the Hedge Fund Standards Board), and a member of Focusing Capital on the Long Term, a nonprofit that works to encourage a longer-term focus in business and investment decision making. We are also part of ESG working groups at the Managed Funds Association (MFA) and Alternative Investment Management Association (AIMA). Finally, the co-chairs of our Sustainable Investing Committee hold various leadership positions on sustainability initiatives such as the G7-backed Impact Taskforce, and the International Foundation for Valuing Impacts, and they share our research and insights regularly at industry sessions and conferences such as Conexus’ Sustainability in Practice Forum at Harvard University.

Quality Control and Compliance in Our Sustainability Efforts

Ensuring a high level of quality control and compliance throughout our sustainable investing effort is of paramount importance to us. We recognize that sustainable investing is still a nascent field with substantial conceptual and analytical challenges, imperfect data, and a lack of clear global standards. To address these challenges, we have designed an objective and systematic sustainability process, backed by a strong governance design, led by senior investors with clear lines of responsibility, and subject to an independent review by Bridgewater’s compliance team.

Apply a rigorous, systematic process: The most important component of our quality control is the fundamental, systematic, and triangulated sustainability assessment process that we have built. Being systematic not only enables us to create quality assessments, but importantly it also requires us to clearly document our logic and automate our processes, which in turn allows us (and our independent compliance team) to ensure adherence to our intended processes and identify areas of weaknesses where we can improve. We approach the challenge with humility; while we are confident in our approach, we also expect our understanding to evolve as the data landscape continues to rapidly grow and as we continue to research the best methods for sustainability assessment.

Clear governance led by senior investors: Our co-CIO Karen Karniol-Tambour and co-CIO for Sustainability Carsten Stendevad are responsible for embedding sustainability considerations across Bridgewater’s investment processes and for designing and overseeing those portfolios that pursue both financial and impact goals. With respect to the All Weather Sustainability and Active Sustainable Equities strategies, they are responsible for all portfolio decisions, both financial and sustainability-related. In addition to the Sustainable Investing Committee, Karen is also a member of Bridgewater’s Executive Committee and Investment Committee, which are responsible for all aspects of the firm’s investment research process, ensuring an ongoing integration across the firm’s investment priorities.

Independent compliance process and testing program: All of Bridgewater’s key business processes, including our sustainable investing processes, are subject to review and are supported by Bridgewater’s independent compliance team, which advises on regulatory matters, monitors Bridgewater’s business activities, and conducts risk-based compliance testing to ensure that we are meeting or exceeding our regulatory obligations. The independent compliance team regularly assesses and adjusts its processes to keep pace with evolving regulatory requirements or industry standards related to sustainability or otherwise.

  1. Bridgewater is deeply committed to meeting or exceeding our regulatory and ethical obligations both to our regulators and to our clients. To make good on this commitment, Bridgewater maintains an independent compliance team, which is led by our Chief Compliance Officer (CCO) and Counsel, Helene Glotzer, who reports directly to our CEO. As CCO, Helene is responsible for the design and implementation of Bridgewater’s compliance program, which involves: (a) understanding the regulatory environment, (b) setting standards and policies to facilitate compliance with regulatory requirements, (c) educating and advising employees about regulatory and policy obligations, and (d) monitoring and testing Bridgewater’s activities and ensuring compliance with policy and regulation. Importantly, Bridgewater’s compliance program is not static, but rather evolves in an effort to keep pace with both the dynamic regulatory environment and changes to Bridgewater’s business activities. To do this well, Helene regularly briefs and advises Bridgewater’s CEO and other senior leaders on regulatory changes and any meaningful findings from compliance monitoring or testing.
  2. In the context of our sustainable investing efforts, Bridgewater’s compliance team operates in the same way. In particular, our compliance team regularly briefs the co-chairs of our Sustainable Investing Committee on key regulatory developments related to sustainable or ESG investing, engages to help set standards and frameworks to inform sustainability efforts, provides regulatory and compliance advice on a variety of matters, and has designed and implemented a monitoring and testing program that serves as an independent double check on certain internal processes. The internal testing program on sustainability is done as part of our ordinary course of business and seeks to evaluate key components of our process, including:

    • Reviewing and probing investor-facing materials, including the contents of our annual sustainable investing report, quarterly letters, due diligence documents, and marketing materials;
    • Reviewing and probing data acquisition and due diligence procedures;
    • Reviewing and probing asset selection criteria; and
    • Reviewing and probing proxy voting and corporate engagement activities.

Supplemental, third-party audit: To ensure that the above governance and systems are working as designed, we proactively seek additional reviews and triangulation from third party experts. In 2022, we executed a formal and holistic testing program of Bridgewater’s sustainable-investing-related policies and practices with ACA Group. Through a thorough review of Bridgewater’s sustainable investing processes and outputs, ACA concluded that Bridgewater’s approach is in line with industry and regulatory best practices—citing the aforementioned systematic research process, the overarching governance structure, and the quality of reporting outputs. ACA also made certain program-enhancing recommendations to further align with regulatory expectations and industry best practices, which we have implemented.

Finally, we have policies in place to identify and mitigate conflicts of interest, which we describe in sections 6, 10, and 12 of Form ADV Part 2A and our Code of Ethics, both of which are available upon request. Bridgewater aims to identify all conflicts of interest that could incentivize, or even give the appearance of incentivizing, Bridgewater employees to make decisions that may not be in the best interest of our clients.

1Note on portfolio exclusions: as it pertains to our asset holdings and exclusion lists, we ensure that we are compliant with all applicable sanctions. We do not have a firmwide exclusion list across portfolios that excludes investments solely for environmental or social impact reasons.

2There can be no guarantee that any expected performance can or will be achieved and expected performance should not be solely relied upon in making any investment decision. We cannot guarantee that any of our strategies with sustainable impact objectives will meet the sustainability objectives of any particular investor. While we assess every asset in our current strategies with sustainable impact objectives to be either aligned to the SDGs overall or on a clear and credible pathway towards overall SDG alignment, we cannot guarantee that any assets will be aligned to any particular SDG or any other particular ESG metric.


Important Disclosures and Other Information

Please read carefully the following important disclosures and other information as they provide additional information relevant to understanding the assumptions, research and performance information presented herein. Additional information is available upon request except where the proprietary nature of the information precludes its dissemination.

This presentation contains proprietary information regarding Bridgewater Associates, LP (“Bridgewater”) and the strategies Bridgewater manages and is being furnished on a confidential basis to a sophisticated prospective investor for the purpose of evaluating an investment with Bridgewater. By accepting this presentation, the prospective investor agrees that it (and each employee, representative or other agent of such prospective investor) will use the information only to evaluate its potential interest in a fund or strategy described herein and for no other purpose and will not divulge any such information to any other party. No part of this presentation may be (i) copied, photocopied or duplicated in any form by any means or (ii) redistributed without the prior written consent of Bridgewater. Notwithstanding anything to the contrary, a prospective investor, and each employee, representative or other agent of such prospective investor, may disclose to any and all persons, without limitation of any kind, the U.S. federal and state income tax treatment and tax structure of a fund described herein (and any of the transactions contemplated hereby) and all materials of any kind (including opinions or other tax analyses) that are provided to a prospective investor relating to such U.S. federal and state income tax treatment and tax structure.

This presentation has been prepared solely for informational purposes and is not an offer to buy or sell or a solicitation of an offer to buy or sell any security or to participate in any trading strategy. Any such offering, will be made pursuant to a definitive offering memorandum (the “OM”) which will contain the terms and risks of making an investment with Bridgewater in the relevant fund and other material information not contained herein and which will supersede this information in its entirety. In the event of any discrepancy between the information shown in this presentation and the OM, the OM will prevail. Investors should not construe the contents of this presentation as legal, tax, accounting, investment or other advice. Any decision to invest in a Bridgewater fund or strategy described herein should be made after carefully reviewing the OM (including the risks described therein) and all other related documents, conducting such investigations as the prospective investor deems necessary and consulting such investor’s own investment, legal, accounting and tax advisors in order to make an independent determination of the suitability and consequences of an investment in such fund or strategy.

An investment in any Bridgewater fund or strategy involves significant risks and there can be no assurance that any fund or strategy will achieve its investment objective or any targets or that investors will receive any return of their capital. An investment in any Bridgewater fund or strategy is suitable only for sophisticated investors and requires the financial ability and willingness to accept the high risks inherent in such an investment (including the risk of loss of their entire investment) for an indefinite period of time. Past performance is not indicative of future results.

This presentation and the OM will only be made available to persons or entities who are “accredited investors” under the Securities Act of 1933, as amended, and “qualified purchasers” under the Investment Company Act of 1940, as amended. The distribution of this presentation and the OM may be restricted by law in certain jurisdictions, and it is the responsibility of persons into whose possession this presentation or the OM comes to inform themselves about, and observe, any such restrictions.

The shares in the fund may not be offered or sold to the public in Brazil. Accordingly, the shares in the fund have not been nor will be registered with the Brazilian Securities Commission - CVM nor have they been submitted to the foregoing agency for approval. Documents relating to the shares in the fund, as well as the information contained therein, may not be supplied to the public in Brazil, as the offering of shares in the fund is not a public offering of securities in Brazil, nor used in connection with any offer for subscription or sale of securities to the public in Brazil.

Certain information contained herein constitutes forward-looking statements (including projections, targets, hypotheticals, ratios, estimates, returns, performance, opinions, activity and other events contained or referenced herein), which can be identified by the use of terms such as “may,” “will,” “should,” “expect,” “anticipate,” “project,” “estimate,” “intend,” “continue” or “believe” or other variations (or their negatives) thereof. Due to various risks, assumptions, uncertainties and actual events, including those discussed herein and in the OM, actual results, returns or performance can differ materially from those reflected or contemplated in such forward-looking statements. As a result, prospective investors should not rely on such forward-looking statements in making their investment decisions. While Bridgewater believes that there is a sound basis for these forward-looking statements, no representations are made as to their accuracy, and there can be no assurance that such results will be achieved. Any forward-looking statements contained herein reflect Bridgewater’s current judgment and assumptions which may change in the future, and Bridgewater has no obligation to update or amend such forward-looking statements.

Bridgewater’s investment process seeks to understand the cause and effect linkages that drive markets over time. To assess and refine its understanding of these linkages, Bridgewater performs historical stress tests across a wide range of time frames and market environments. From these stress tests, Bridgewater is able to simulate how its strategies would have performed prior to their inception. Bridgewater has the ability to run multiple simulations and select the simulation with the best results, returns or performance. For strategies that include active decision making, Bridgewater often “humbles” its simulated alpha returns (by systematically adjusting downward the simulated results that Bridgewater’s current alpha investment logic produces) to account for the possibility that it could be wrong. Because this stress testing is a core component of Bridgewater’s investment process, it shares these simulations with current and prospective investors to demonstrate its thinking. However, because they do not demonstrate actual results, these simulations are hypothetical, and inherently limited and should not be relied upon to make an investment decision.

The recipient should not solely rely upon these hypothetical performance results in making an investment decision. In constructing hypothetical performance and determining their appropriateness for use in materials, Bridgewater has an incentive to do so in a manner that shows beneficial characteristics of a given, hypothetical return stream.

All hypothetical performance is subject to revision and provided solely as a guide to current expectations. The recipient should not solely rely upon these hypothetical performance results in making an investment decision. Hypothetical performance results can provide insight into the level of risk that a strategy will seek with respect to its investments, with higher hypothetical performance results generally reflecting greater risk. Some or all results may be substantially lower than these hypothetical results and, as with any investment, there is a risk of loss of the entire investment.

Hypothetical performance results rely on numerous criteria, assumptions, risks and limitations and are inherently uncertain. There are multiple assumptions and possible adjustments Bridgewater may make in its underlying calculations that are reasonable, but other criteria, assumptions, methodologies and adjustments could also be reasonable and could lead to materially different and lower actual results and higher risks than those presented. In addition, the hypothetical performance results may prove to be invalid, inaccurate, incomplete or change without notice. Variation in any of these factors (or factors or events that are unknown or unaccounted for) could cause actual returns to substantially differ. In constructing hypothetical returns and determining their appropriateness for use in materials, Bridgewater has an incentive to do so in a manner that shows beneficial characteristics of a given, hypothetical return stream. Furthermore, any hypothetical or mathematical calculations or data might contain errors, and could rely on third-party inputs, which Bridgewater believes to be reliable but whose accuracy cannot be guaranteed.

While Bridgewater believes that there is a sound basis for these hypothetical performance results, no representations are made as to their accuracy, and there can be no assurance that such results will be achieved. This presentation will not be updated or amended even if there are changes in the information or processes upon which they rely.

Bridgewater believes that a particular return stream should be evaluated against its expected performance or its benchmark. To that end, Bridgewater demonstrates whether its strategies are operating as expected via a cone chart, which shows the performance of a particular strategy over time relative to the strategy’s benchmark and also within bands of standard deviation from that benchmark. Separately, to demonstrate the impact of market conditions on the strategies it manages, Bridgewater explains the macro-economic pressures and market conditions that effected performance in the context of client letters, account reviews, or other publications that Bridgewater provides to each current and prospective investor on a regular basis. Additional information about how Bridgewater thinks about setting expectations for its strategies via a benchmark is available upon request.

Any tables, graphs or charts relating to past performance, whether hypothetical, simulated or actual, included in this presentation are intended only to illustrate the performance of indices, strategies, or specific accounts for the historical periods shown. When creating such tables, graphs and charts, Bridgewater may incorporate assumptions on trading, positions, transactions costs, market impact estimations and the benefit of hindsight. For example, transaction cost estimates used in simulations are based on historical measured costs and/or modeled costs, and attribution is derived from a process of attributing positions held at a point in time to specific market views and is inherently imprecise. Such tables, graphs and charts are not intended to predict future performance and should not be used as a basis for making any investment decision. Bridgewater has no obligation to update or amend such tables, graphs or charts.

Statements regarding target performance or target ratios related to assumed risk budgets, liabilities, volatility, target volatility, tracking error or other targets are hypothetical in nature and should not be considered a guarantee that such results can or will be achieved. For example, Bridgewater may adjust returns to match, for instance, the annualized standard deviation of two or more return series but this adjustment does not suggest that the returns or assets are similar with respect to other aspects of the risk such as liquidity risk. Any statements with respect to the ability to risk match or risk adjust in the future are not a guarantee that the realized risks will be similar and material divergences could occur. All performance and risk targets contained herein are subject to revision by Bridgewater and are provided solely as a guide to current targets.

Discussions related to the risk controlling capabilities of low risk portfolios, diversification, passive investing, risk management, risk adjusting, and any other risk control theories, statements, measures, calculations and policies contained herein should not be construed as a statement that Bridgewater has the ability to control all risk or that the investments or instruments discussed are low or will lower any risk. Active trading comes with a monetary cost and high risk and there is no guarantee the cost of trading will not have a materially adverse impact on any account, fund, portfolio or other structure. Bridgewater manages accounts, funds and strategies not referred to herein. For such accounts, funds and strategies, and, even where accounts, funds or strategies are traded similarly, performance may materially diverge based on, among other factors, timing, the approved instruments, markets, and target risk for each strategy or market. The price and value of the investments referred to in this presentation and the income, if any, derived therefrom may fluctuate.

Bridgewater uses different types of performance in its materials. Unless otherwise indicated, such types of performance can be understood as follows:

Hypothetical Performance refers to any return stream that is not actual performance. Hypothetical performance includes, for example, Simulated Performance and Related Fund or Related Share Class Performance.

Simulated Performance refers to hypothetical performance that shows the returns of a Bridgewater strategy prior to its inception date. Simulated performance does not reflect actual trading by Bridgewater and is constructed by applying Bridgewater’s investment management process to available market data.

Related Fund or Related Share Class Performance refers to actual performance that has been adjusted to account for volatility and/or currency differences. Because it is based on actual performance, Related Fund or Related Share Class Performance does reflect actual trading by Bridgewater, which has been adjusted on the basis of currency, volatility, or both and is thus hypothetical. Note that the terms Related Fund or Related Share Class Performance are not being used in the same way that the term ‘Related Performance’ is used in the Securities and Exchange Commission’s Marketing Rule.

Statistical and mathematical measures of performance and risk measures based on past performance, market assumptions or any other input should not be relied upon as indicators of future results. While Bridgewater believes the assumptions and possible adjustments it may make in making the underlying calculations are reasonable, other assumptions, methodologies and adjustments could have been made that are reasonable and would result in materially different results, including materially lower results. Where shown, targeted performance and the abilities and capabilities of the active and passive management approaches discussed herein are based on Bridgewater’s analysis of market data, quantitative research of the underlying forces that influence asset classes as well as management policies and objectives, all of which are subject to change. The material contained herein may exhibit the potential for attractive returns, however it also involves a corresponding high degree of risk. Targeted performance, whether mathematically based or theoretical, is considered hypothetical and is subject to inherent limitations such as the impact of concurrent economic or geo-political elements, forces of nature, war and other factors not addressed in the analysis, such as lack of liquidity. Please see additional discussions of hypothetical performance herein for important information on the risks and limitations thereof. There is no guarantee that the targeted performance for any fund or strategy shown herein can or will be achieved. A broad range of risk factors, individually or collectively, could cause a fund or strategy to fail to meet its investment objectives and/or targeted returns, volatilities or correlations.

Where shown, information related to markets traded may not necessarily indicate the actual historical or current strategies of Bridgewater. Markets listed might not be currently traded and are subject to change without notice. Markets listed are used for illustrative purposes, may not represent the universe of markets traded or results available and may not include actual trading results of Bridgewater. Other markets or trading, not shown herein, can have had materially different results. Attribution of performance or designation of markets and the analysis of performance or other performance with respect to scenario analysis or the determination of biases is based on Bridgewater’s analysis. Statements made with respect to the ability of Bridgewater, a fund, a strategy, a market or instrument to perform in relation to any other market, instrument or manager in absolute terms or in any specific manner in the future or any specified time period are not a guarantee of the desired or targeted result.

Bridgewater research utilizes data and information from public, private and internal sources, including data from actual Bridgewater trades. Sources can include, Arabesque ESG Book, Bloomberg Finance L.P., Bond Radar, Candeal, Capital Economics, CBRE, Inc., CEIC Data Company Ltd., Clarus Financial Technology, Conference Board of Canada, Consensus Economics Inc., Corelogic, Inc., Cornerstone Macro, Dealogic, DTCC Data Repository, Ecoanalitica, Empirical Research Partners, Entis (Axioma Qontigo), EPFR Global, Eurasia Group, Evercore ISI, Factset Research Systems, The Financial Times Limited, FINRA, GaveKal Research Ltd., Global Financial Data, Inc., Harvard Business Review, Haver Analytics, Inc., Institutional Shareholder Services (ISS), The Investment Funds Institute of Canada, ICE Data, ICE Derived Data (UK), IHSMarkit, Investment Company Institute, International Institute of Finance, JP Morgan, MarketAxess, Medley Global Advisors, Metals Focus Ltd, London Stock Exchange Group, Moody’s ESG Solutions Group, MSCI, Inc., National Bureau of Economic Research, OAG Aviation, Organisation for Economic Cooperation and Development, Pensions & Investments Research Center, Refinitiv, Rhodium Group, RP Data, Rystad Energy, S&P Global Market Intelligence, Sentix Gmbh, Shanghai Wind Information, Sustainalytics, Swaps Monitor, Totem Macro, Tradeweb, United Nations, US Department of Commerce, Verisk Maplecroft, Visible Alpha, Wells Bay, Wood Mackenzie Limited, World Bureau of Metal Statistics, World Economic Forum, YieldBook. While we consider information from external sources to be reliable, we do not assume responsibility for its accuracy.

None of the information related to a fund or strategy that Bridgewater provides is intended to form the basis for any investment decision with respect to any retirement plan’s (or any investor’s) assets. Any information Bridgewater provides should be independently and critically evaluated based on whatever other sources are deemed appropriate, including legal and tax advice; it is also not intended to be impartial investment information or advice as Bridgewater can recommend one or more Bridgewater products in connection with such information, which would result in additional fees being paid to Bridgewater. Bridgewater’s status as an ERISA fiduciary with respect to the management of any existing or future Bridgewater product(s) in which you invest would be (or continue to be) set forth in that product’s applicable governing instruments. You are responsible for ensuring that your decision to invest in any Bridgewater product does not violate the fiduciary or prohibited transaction rules of ERISA, the U.S. Internal Revenue Code or any applicable laws or regulations that are similar. On and after June 9, 2017, the information provided herein is being made available only to “independent fiduciaries with financial expertise” (within the meaning of the Definition of the Term “Fiduciary”; Conflict of Interest Rule – Retirement Investment Advice, 81 Fed. Reg. 20,946 (Apr. 8, 2017), available at https://www.gpo.gov/fdsys/pkg/FR-2016-04-08/pdf/2016-07924.pdf), and this presentation should not be accepted by any person who does not meet such requirements.

This presentation was written in connection with the promotion or marketing of a Bridgewater fund or strategy, and it was not intended or written to be used and cannot be used by any person for the purpose of avoiding penalties that may be asserted under the U.S. Internal Revenue Code.

In certain instances amounts and percentages in this presentation are approximate and have been rounded for presentation purposes. Statements in this presentation are made as of the date appearing on this presentation unless otherwise indicated. Neither the delivery of this presentation or the OM shall at any time under any circumstances create an implication that the information contained herein is correct as of any time subsequent to such date. Bridgewater has no obligation to inform potential or existing investors when information herein becomes stale, deleted, modified or changed. ©2024 Bridgewater Associates, LP. All rights reserved.

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